Outline:

1 | Overview: Why Experience Requirements Matter

FAA regulations for commercial pilot certification are detailed in 14 CFR §61.129. Understanding and logging them correctly ensures you meet eligibility before the checkride.

• The minimum is 250 total flight hours for airplanes, but time breakdowns matter.

• Requirements specify dual, solo/PDPIC, cross-country, instrument, and night training.

• Logging errors are a common reason applicants face delays or retests.

2 | Total Hours Breakdown (§61.129)

Pilots must accumulate specific hours in various categories.

• 250 total time, including:

  • 100 hours in powered aircraft (50 in airplanes).

  • 100 hours PIC (50 in airplanes, 50 cross-country).

• This ensures broad operational experience across conditions and environments.

3 | Dual Instruction Requirements

At least 20 hours of dual training are required with a CFI.

• Must include training in complex, turbine, or TAA aircraft (10 hours in any combination).

• At least 10 hours of instrument training by a CFII. If you already hold an instrument rating, verify 5 hours are in a single-engine airplane.

• Dual cross-country: 2 hrs day (>100 nm) + 2 hrs night (>100 nm).

• 3 hours of prep within 2 calendar months before the checkride.

4 | Solo and PDPIC (Performing Duties of PIC)

Applicants need 10 hours of solo or PDPIC in airplanes.

• Must include one cross-country of at least 300 nm, with one leg over 250 nm and landings at 3 different airports.

• Also requires 5 hours night VFR with 10 takeoffs and landings at a towered airport.

• PDPIC definition: Flying with a CFI onboard but acting as PIC (log in remarks, not as dual).

5 | Logging Time Correctly

Accurate logging is critical to prove eligibility.

• Training time and PDPIC cannot be combined — they must be logged separately.

• Instrument training must specify view-limiting device, partial panel, unusual attitudes per 61.129(a)(3)(i).

• Log entries should use exact FAR wording (e.g., “61.129(a)(4)(i)”).

• If dual also meets IFR requirements, note this clearly in the remarks.

6 | Dual vs Solo Clarifications

A common mistake is confusing dual with solo/PDPIC requirements.

• 20 hours of dual may not overlap with the 10 hours of solo/PDPIC.

• Instructors should explain when time qualifies as PIC versus dual received.

7 | Night Training Clarification

FAA Part 1 defines night as civil twilight to morning civil twilight.

• Solo/PDPIC and dual night training may begin at civil twilight, not “1 hr after sunset” (that rule applies to passenger-carrying currency under 61.57).

• This detail matters for logging cross-country and solo night flights correctly.

8 | Initial Certification vs Additional Ratings

Requirements differ depending on whether it’s your first commercial certificate or an additional category/class rating.

• Initial ASEL: Must meet the full 250-hour breakdown. XC logged before your Private does not count toward commercial.

• Additional Category (61.63): Lower minimums apply for rotorcraft or balloons. For example, rotorcraft/helicopter = 150 hrs, balloon = 25 hrs.

• Pilots adding airplane privileges must complete PDPIC time and solo endorsements per AC 61-65J.

9 | Endorsements & Testing

All endorsements must follow AC 61-65H wording.

• Knowledge test: not required for additional category/class at same certificate level.

• Practical test: evaluated against ACS Appendix 1 tasks.

• Endorsements for complex, high-performance, tailwheel, or high altitude may also apply depending on the aircraft flown.